Switzerland is a more attractive model than Norway, but Britain could do better than either

Supporters of EU membership keep warning that we might end up like Norway. Oslo, they tell us in scary voices, is 'governed by fax'. Its leaders, apparently, are sitting by their fax machines waiting for the latest directives to flop through from Brussels. As a member of the European Economic Area (EEA), Norway has to apply Euro-laws over whose drafting it has had no say.

What is it with Euro-enthusiasts and their antiquated metaphors? They tell us that we're stuck in the past, and then they start banging on about fax machines! But set that aside. Set aside, too, the fact that the Norwegians plainly prefer their existing status to the full membership enjoyed by Britain: no fewer than 79.8 per cent of them oppose joining the EU. Let's deal with the substance of the charge.

The short answer to the 'government-by-fax' merchants is that almost no British Eurosceptic is proposing that we copy Norway. Let me repeat that, because it doesn't seem to be getting through to the BBC or, indeed, to Number Ten: Almostno British Eurosceptic wants to copy Norway. Our preferred model – with some adjustments – is Switzerland. It's worth taking a moment to explain the difference.

On the surface, Norway and Switzerland have similar arrangements with the EU. Both are members of the European Free Trade Association and of Schengen. Both enjoy full access to the EU's single market without being part of the Common Agricultural Policy, the Common Fisheries Policy, the European Court, Commission or Parliament, the shared jurisdiction in the fields of justice and home affairs or the Common Foreign and Security Policy. Both countries, critically, are able to sign free trade accords with non-EU states – much the greatest advantage in the present global economy. Both, in short, have a far better deal than the United Kingdom has.

But there is a difference. Norway is a member of the European Economic Area (EEA) while Switzerland is not. The EEA was negotiated in 1992, when Austria, Finland, Norway and Sweden applied for full membership of the EU. It was only ever envisaged as a transitional arrangement: a way to expedite harmonisation on the way to full accession. No one ever envisaged that Norway would vote 'No' to the EU, but still be in the EEA 20 years later.

The chief anomaly in the EEA – the fact that Norway has to apply EU laws over which it has had no say – is more of a problem in theory than in practice. According to the EU, Norway has had to impose more than 5,000 EU legal acts since 1992. Yet Britain, over the same period, had to apply more than 3,000 every year. And most of the Norwegian directives are technical and trivial: the order in which to list ingredients on a ketchup bottle, the font size on a packet of chewing gum and the like. Implementing these 5,000 directives has required fewer than 100 pieces of primary legislation in the Stortinget.

These figures, I should stress, are the EU's. According to the Norwegians themselves, their exposure to Brussels legislation is far slighter. In 2004, in reply to a parliamentary question, the Norwegian government declared that, of 11,511 pieces of EU legislation adopted between 1997 and 2003, Norway had had to adopt 2,129: 18.5 per cent. A survey in 2010 covering the period from 2000 to 2009 found the figure to be just 8.9 per cent.

Still, the anomaly is there. Never mind whether it's 8.9 per cent or 18.5. Never mind that, in practice, Norway maintains a large representative office in Brussels to ensure that its concerns are heard when the legislation is being proposed. Formally, there is a chunk of Norwegian law which has, as the PM says, been made in Brussels without official Norwegian input. Why does this happen to Norway but not to Switzerland?

The main reason is that Swiss politicians, unlike their Norwegian counterparts, listened to their voters. When Switzerland rejected EEA membership in a referendum in 1992, that was that. Although almost all the political parties had wanted to join both the EEA and the EU, they accepted the people's verdict. With EU membership off the agenda, they sat down to discuss an alternative. Over the next three years, 120 sectoral treaties were negotiated, covering everything from lorry noise to fish farming. In consequence, Switzerland has most of the benefits of full membership, but few of the costs. It is wholly covered by the four freedoms of the single market – free movement, that is, of goods, services, people and capital – but it is spared the regulatory burden of Brussels directives. When it harmonises its standards with those of the EU, it does so through bilateral agreement and following a deliberate act of the Federal Assembly in Bern.

Yes, Swiss exporters must meet EU standards when selling to the EU, just as they must meet Japanese standards when selling to Japan. But they are not obliged to apply these standards, either to their domestic economy, or to their non-EU exports. Being outside the Common External Tariff, they have pursued a much less protectionist policy than the EU and are now, among other things, negotiating a free trade agreement with China – something Britain cannot do while it is in the EU. Switzerland is unrepresented in the Brussels institutions, and makes only a token contribution to the EU budget. Not that this prejudices its trade with the EU: Swiss exports to the EU in 2011 were 450 per cent per capita what Britain's were. That, too, is worth repeating. Last year, the Swiss, in population terms, sold four-and-a-half times as much to the EU from outside as we did from inside.

Why, then, don't the Norwegians copy the Swiss? Why, 20 years on, do they keep the lopsided EEA agreement in place? Because their politicians still hanker after eventual membership. Replacing the EEA with something more permanent would mean formally accepting that their dream was over. Indeed, a cynic might say that it suits Europhile Norwegian politicians to retain the imperfections of the EEA. It allows them to say to their sceptical electorate: 'Look, since we have to apply all these laws anyway, we might as well go the whole hog and join!' The same reasoning explains why Norway pays so much more to the EU budget than is required under the EEA treaty. When I asked officials in the Norwegian foreign office why they paid so much more than Iceland (which is an EEA member on precisely the same terms as Norway), they gave me some waffle about wanting to participate in foreign aid, research and social projects. When I put the same question to their Icelandic counterparts, two civil servants looked at each other awkwardly, and one said: 'Because those Norwegian Euro-officials are f***ing crazy!'

Happily, there is no sign that the level-headed Norwegian people are being taken in. Opinion polls have registered a two-to-one majority or more against EU membership for so long that, earlier this year, the pro-accession campaign admitted defeat and suspended operations.

So, to summarise, Norway has a much better deal than the UK, but Switzerland's is better than either. Our objective, when we leave the EU, should be to aim for a Swiss model, based on bilateral accords, rather than membership of the EEA – though naturally adjusted to our own conditions. There is no reason we shouldn't do better even than the Swiss. We are 62 million people to Norway's 4 million and Switzerland's 7 million. We run a massive trade deficit with the EU (but a surplus with the rest of the world). On the day we left, we'd become the EU's single biggest market, accounting for 21 per cent of its exports – more than its second and third largest markets (the US and Japan) combined. That's not to say that we should precisely replicate the Swiss deal: there is no reason for us to join Schengen, for example. But the Swiss offer a useful template. In the mean time, my Europhile friends, please stop banging on about Norway and faxes. You're railing against something that no one is suggesting.

UPDATE: Right on cue, here's a piece in the Observer: 'The Tory Little Englanders want out of Europe and cite Norway's riches…' Setting aside the fact that the article incongruously appears in news, not comment, the writer might want to look up 'Little Englander'.